Ensure that the newly developed procedures are sufficient and fully implemented to ensure that the source of funds loaned is properly tracked and that payments received are applied to the appropriate accounts.

Support the reasonableness of the $258,412 paid for contract M-1449 or reimburse its Capital Fund program from non-Federal funds.

Support that the contract modification totaling $4,899 for contract number M-1449 was reasonable. The amount that cannot be shown to be reasonable should be reimbursed to its Capital Fund program from non-Federal funds.

Implement adequate procedures and controls to ensure that it complies with HUD’s procurement requirements.

Ensure that its staff is properly trained and familiar with HUD’s requirements to ensure that documentation necessary to support the reasonableness of contract costs is obtained and maintained.

Implement adequate procedures and controls to ensure that capital funds are drawn down and disbursed in accordance with HUD’s requirements.

Implement adequate procedures and controls to ensure that it properly reports its expenditures and disbursements in LOCCS in accordance with HUD’s requirements.

Adequately support or reimburse its NSP3 grant subrecipient $53,760 from non-Federal funds for the disbursements not adequately supported.

Update its records retention policy to meet HUD’s records retention requirements and notify its NSP subrecipients of the documentation retention requirements for the NSP grants.

Develop a retention strategy for its subrecipients to ensure that documentation is readily available for review.

Repay from non-Federal funds the $665,920 in ineligible costs charged to the program

Support that 14 projects, with $494,517 in construction costs, met the environmental review requirements and repay from non-Federal funds any amounts attributed to projects that cannot be certified.

Provide additional guidance to their grantees and strengthen controls to ensure that tier two environmental reviews are performed and properly conducted and signed by the responsible entity before committing program funds.

Support $401,870 for contracts that were awarded without an independent cost estimate or repay from non-Federal funds any amount that cannot be supported.

Provide additional guidance to their grantees and strengthen controls over procurement to ensure that grantees follow applicable State and Federal procurement requirements, including obtaining independent cost estimates and ensuring full and open competition.

Define which expenses should be considered program delivery costs and strengthen controls over program costs to ensure that costs are properly charged.

Require the Commonwealth to provide documentation to substantiate the eligibility of $150,000 provided to Southampton or repay the HOME program from nonfederal funds.

Support that it met its $161,957 matching contribution required for the $647,827 it drew down for expenses related to its four HUD-funded programs. If the Community cannot provide support, it should reimburse HUD $577,6707 from non-Federal funds.

Develop and implement written policies and procedures to ensure that it maintains documentation to support matching contributions received in compliance with HUD requirements.

Repay HUD $15,163 from non-Federal funds for the rental assistance provided to five ineligible individuals.